Modern Slavery Act Statement

This document is approved and authorised for application within
Morgan Hunt Ltd and all associated subsidiary companies.
Signed

Dan Taylor, Managing Director
Last Review Date: February 2026

Morgan Hunt UK Limited (“the Company”) is a privately-owned company registered in England and Wales. The Company is carrying on business in the UK as a recruitment business specialising in recruiting professionals and blue-collar workers into a wide range of public services including but not limited to: education, health, government, housing, social care and charities.

The Company was established in 2002 and today operates out of offices in the City of London, Glasgow, Manchester & Birmingham. The Company currently employs fewer than 220 people but engages, supplies and pays in excess of 2000 temporary agency workers through its payroll, in its capacity as a temporary staffing company. The Company turns over in excess of £36 million each financial year and is therefore a commercial organisation required to publish an annual slavery and human trafficking statement under section 54 of the Modern Slavery Act 2015 (see “Annual Modern Slavery Statement” below). The Company treats the threat of modern slavery as a matter of the utmost importance.

The Company is committed to the highest standards of integrity, transparency and accountability. It is therefore vital that it can demonstrate that all appropriate steps are taken to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its own business.

To hold an individual in slavery is a violation of fundamental human rights and a crime. The Company recognises this takes various forms, such as slavery, servitude, forced/compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another for the purposes of exploiting them for personal or commercial gain. Accordingly, guidance on how to recognise and respond to the signs of modern slavery is published for the Company’s employees together with this Modern Slavery Policy which sets out how the Company aims to prevent, detect and report modern slavery in any part of its business or supply chains.

The Company takes a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships and in implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its UK business operations or in any of the Company’s supply chains. The Company has an internal Training and Development department which is responsible for ensuring all staff’s training and development needs are met including around the identification and reporting of concerns around modern slavery. The Company expects the same high standards from its suppliers, contractors and other third parties. As part of the Company’s contracting processes, it expects that its suppliers will hold their own suppliers to the same standards set out in our policy statement below.

All staff and third parties are required to raise any concerns about any issue or suspicion of modern slavery in any parts of the Company’s business or supply chains at the earliest possible stage. The Company encourages openness and will support anyone who raises genuine concerns under this Modern Slavery Policy, even if they turn out to be mistaken. The Company is committed to ensuring no one suffers any detrimental treatment as a result of reporting their reasonable suspicion that modern slavery of whatever form is or may be taking place in any part of the business or in any of the Company’s supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If any staff believe they have suffered any such treatment, the individual is encouraged to inform either their manager or the HR Department immediately and to report the matter to the proper authorities. Staff who make a qualifying disclosure in the public interest are also protected from detriment and dismissal under the Public Interest Disclosure Act 1998, and may raise concerns under the Company’s Whistleblowing Policy.
The Company fully supports all national and international efforts to promote ethical principles and work practices and in particular the efforts to prevent exploitation and abuse associated with modern slavery and human trafficking.

The board of directors has overall responsibility for ensuring this Company’s Modern Slavery Policy complies with the Company’s legal and ethical obligations, and that all those Staff and third parties under its control comply with it and has approved this Statement.

The board of directors has nominated [insert name and job title] as the Board-level lead for modern slavery. The Board-level lead is accountable for overseeing the implementation of this Policy, receiving regular reports from Compliance on modern slavery risks, concerns raised and the key performance indicators set out under “Monitoring and Review of the Policy”, and ensuring that adequate resources are made available to manage modern slavery risk.

Policy Scope

This policy applies to all persons working for the Company or on its behalf in any capacity, including employees at all levels, directors and officers (“Staff”) and third parties including agency workers, customers, suppliers, umbrella companies and other payroll intermediaries, second-tier recruitment agencies, seconded workers, volunteers, interns, agents, contractors and external consultants (“Third Parties”). It applies to all of the Company’s offices and operations in England, Scotland and elsewhere in the UK.

Purpose of the Policy

This policy describes how the Company will prevent, detect and report modern slavery in any part of its business or supply chains.

Legislative Framework

This Policy has been prepared having regard to the following legislation and guidance, as amended from time to time:

Modern Slavery Act 2015 – which creates the offences of slavery, servitude and forced or compulsory labour (section 1) and human trafficking (section 2), and which requires commercial organisations with a total annual turnover of £36 million or more to publish an annual slavery and human trafficking statement (section 54).
Transparency in Supply Chains etc.: A Practical Guide – the Home Office statutory guidance on section 54, updated in March 2025.
Human Trafficking and Exploitation (Scotland) Act 2015 – which applies to the Company’s operations in Scotland, including its Glasgow office.
Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003 – including the prohibition on charging work-seekers fees for finding them work, and the requirement to provide agency workers with a Key Information Document and written terms.
National Minimum Wage Act 1998, the Working Time Regulations 1998 and the Agency Workers Regulations 2010.
Immigration, Asylum and Nationality Act 2006 – which requires right to work checks to be carried out before any worker is engaged.
Public Interest Disclosure Act 1998 – which protects workers who raise qualifying concerns (whistleblowing).
Employment Rights Act 2025 – including the establishment of the Fair Work Agency, which since April 2026 has enforced the national minimum wage, employment agency standards and labour exploitation matters previously handled by the Gangmasters and Labour Abuse Authority.
Procurement Act 2023 and Procurement Policy Note 009 (Tackling Modern Slavery in Government Supply Chains) – which govern how the Company’s public sector clients assess modern slavery risk in their suppliers, including the Company.

Compliance With the Policy

All staff and third parties must comply with the Modern Slavery Policy and avoid any activity that might lead to, or suggest, a breach of the Policy .
All staff and third parties are required to raise any concerns about any issue or suspicion of modern slavery in any parts of the Company’s business or supply chains of any supplier tier at the earliest possible stage.

If any Staff believe or suspect a breach of this Policy has occurred or that it may occur the individual must notify either their manager and/or Compliance as soon as possible.

If Staff are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of the Company’s supply chains constitutes any of the various forms of modern slavery, this should be raised to Compliance as soon as possible.

All managers are responsible for ensuring that the Modern Slavery Policy and the Company’s zero-tolerance approach to modern slavery is communicated to all employees. And for ensuring those individuals reporting to them understand and comply with the policy and are given adequate and regular training as applicable on the policy and the issue of modern slavery in supply chains.

Management have day-to-day responsibility for implementing the policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

All managers who are responsible for procurement of goods and/or services must ensure that the Modern Slavery Policy and the Company’s zero-tolerance approach to modern slavery is communicated to all third parties during the procurement process and/or at the outset of each business relationship.

Any employee who breaches this policy will face disciplinary action in accordance with the Company’s Disciplinary Policy, which could result in dismissal for misconduct or gross misconduct and/or referral to the authorities.

Reporting Concerns and Responding to Suspected Modern Slavery

Anyone who suspects that a person is a victim of modern slavery, whether a candidate, temporary agency worker, a worker employed by a supplier or anyone else, should follow the steps below:

Immediate danger: if a person is in immediate danger, call the police on 999.
Report internally: in all other cases, report the concern as soon as possible to your manager and to Compliance, recording what was seen or heard, when, and who was involved. Do not confront the suspected perpetrator or make promises to the potential victim that cannot be kept, and do not attempt to investigate the matter yourself.
External reporting: Compliance will decide, with the Board-level lead where appropriate, whether to report the matter to the police (101), the Modern Slavery & Exploitation Helpline (08000 121 700, available 24 hours a day) or the Fair Work Agency. Staff and Third Parties may also contact the Helpline directly and anonymously.
National Referral Mechanism: the Company is not a designated First Responder under the National Referral Mechanism (NRM). Where a potential victim is identified, the Company will refer the matter to the police or another First Responder organisation, which can make an NRM referral (with the consent of an adult potential victim; referral of a child does not require consent). Any concern involving a person under 18 will always be reported.
Confidentiality and data protection: information about potential victims and concerns raised will be handled confidentially, shared only on a need-to-know basis and in accordance with the UK GDPR and the Data Protection Act 2018.
Remediation: where modern slavery is identified in the Company’s own operations, the Company will prioritise the safety and welfare of the affected individual(s), ensure that any wages lawfully due are paid, and take steps to prevent recurrence. Where it is identified in a supply chain, the Company will work with the supplier on a time-bound remediation plan where it is safe and appropriate to do so.
Records: Compliance will keep a confidential log of all concerns raised, the action taken and the outcome, which will inform the annual risk assessment and modern slavery statement.

Supply Chain Due Diligence

The Company procures the services of certain UK based suppliers, an up to date list of which is retained by the Accounts team overseen by the Finance Director. These suppliers provide a range of goods and services to assist the Company’s business, including IT and other professional services such as legal and accountancy, stationery supplies and office cleaning services. As part of its due diligence when procuring services the Company requires each supplier to comply with relevant legislation, including the Modern Slavery Act 2015.

Risk assessment: Compliance will carry out and document a modern slavery risk assessment of the Company’s operations and supply chains at least annually. The Company recognises that its highest areas of risk are: (i) the supply of temporary agency workers, particularly into lower-paid, blue-collar, cleaning, facilities and social care roles; (ii) the use of umbrella companies and other payroll intermediaries to pay temporary workers; (iii) the use of second-tier recruitment agencies; and (iv) outsourced services with labour-intensive workforces, such as office cleaning. Higher-risk suppliers will be subject to enhanced due diligence.

Supplier onboarding: new suppliers in higher-risk categories will be asked to complete a modern slavery due diligence questionnaire and to provide a copy of their modern slavery statement or policy before being approved.
Contract terms: supplier contracts will require compliance with the Modern Slavery Act 2015, prompt notification to the Company of any actual or suspected modern slavery, the flow-down of equivalent obligations to sub-contractors, co-operation with audits and information requests, and a right for the Company to terminate for breach.
Umbrella companies and payroll intermediaries: the Company will only work with umbrella companies on its approved supplier list. Approved umbrella companies must hold accreditation from a recognised compliance body, will be subject to periodic audits (including sample payslip checks to confirm that workers receive at least the national minimum wage and that no unlawful deductions are made), and must comply with the regulation of umbrella companies under the Employment Agencies Act 1973 once in force.
Public sector clients: the Company will co-operate with contracting authorities’ modern slavery due diligence under the Procurement Act 2023 and PPN 009, including completing any modern slavery assessment and providing supply chain information on request.

The Company supplies its services into the sectors detailed within this policy document. It does not experience regular seasonal surges in demand except in education where activity drops significantly during the school holiday periods.

The Company includes a provision in its standard terms of business with its clients in which each party warrants to the other that it takes all reasonable steps to prevent the exploitation and abuse associated with modern slavery and human trafficking.

Where a supplier or other third party breaches the Modern Slavery Policy, the Company will normally require it to take prompt remedial action. The Company may terminate its relationship with the third party where it fails to remediate, where the breach is serious, or where continuing the relationship would put workers at further risk.

Monitoring and Review of the Policy

The Compliance Department has overall responsibility for reviewing the Modern Slavery Policy. The Policy will be reviewed at least annually, and sooner following any change in legislation or statutory guidance, a significant incident or a material change to the Company’s business or supply chains. Any revised Policy will be approved by the board of directors.

The effectiveness of this Policy will be measured against the key performance indicators set out under “Measuring Effectiveness: Key Performance Indicators” below.

Measuring Effectiveness: Key Performance Indicators

In line with section 54(5)(e) of the Modern Slavery Act 2015 and the Home Office statutory guidance, the Company will measure its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains against the key performance indicators (“KPIs”) below. The Board will confirm the targets each year; the targets shown are the Company’s initial targets [to be confirmed by the Board].

Training

Percentage of new Staff completing modern slavery training within one month of starting. Target: 100%.
Percentage of all Staff completing annual refresher training, and of Staff in higher-risk roles completing enhanced training. Target: 100%.

Supply chain due diligence

Percentage of higher-risk suppliers (including umbrella companies) completing modern slavery due diligence before being approved. Target: 100%.
Percentage of approved umbrella companies audited during the year, including sample payslip checks. Target: 100%.
Percentage of new or renewed supplier contracts containing the Company’s modern slavery clauses. Target: 100%.
Number of supplier non-conformities identified, the percentage remediated within the agreed timescale, and the number of supplier relationships ended.

Worker safeguards in the Company’s own operations

Percentage of temporary agency workers whose identity and right to work checks were completed before their first assignment. Target: 100%.
Number of registration flags raised (for example, shared bank accounts, addresses or contact details) and the percentage reviewed by Compliance within five working days. Target: 100%.
Percentage of temporary agency workers given information on how to raise concerns, including the Modern Slavery & Exploitation Helpline. Target: 100%.
Number of worker complaints about pay, deductions or fees, and the number of national minimum wage underpayments identified and corrected.
Reporting and remediation
Number of modern slavery concerns raised (by Staff, temporary agency workers and Third Parties), the percentage triaged by Compliance within two working days (Target: 100%), the outcomes, and the number of referrals to the police, the Helpline or the Fair Work Agency.

Continuous improvement

Percentage of actions identified in the previous year’s risk assessment and modern slavery statement completed within the year. Target: 100%.

Compliance will report performance against these KPIs to the Board-level lead at least quarterly and to the board of directors annually. Where a KPI is not met, Compliance will identify the reasons and agree corrective actions with the Board-level lead. The Company recognises that a low number of reported concerns does not, on its own, show that modern slavery is not occurring, and will consider the KPIs together with the findings of audits, risk assessments and feedback from workers.

The annual modern slavery statement will report the Company’s performance against each KPI, compare it with previous years, and explain what the results show about the effectiveness of the steps taken and any changes the Company will make as a result.

Special Issues Relating to the Supply of Temporary Agency Workers

Morgan Hunt operates in both the permanent and temporary recruitment markets in all the sector disciplines it serves. When introducing candidates into the direct employment of the client employer the Company operates as an employment agency as defined by the Employment Agencies Act 1973 (as amended). The resulting contractual employment relationship is directly between the candidate introduced by the Company and the employing client who engages them directly and controls their day to day activities as their substantive employer.

When supplying a temporary agency worker to client hirers, the Company acts as an employment business as defined by the Employment Agencies Act 1973 (as amended), and engages the worker supplied into each temporary assignment, under a contract for services. This does not give rise to an employment relationship either between the Company and the temporary agency worker or the client and the temporary agency worker. The temporary agency worker is nevertheless a worker as defined by the Employment Rights Act 1996 and is entitled to all ‘worker’ rights under the employment legislation including, but not limited to, the right to be paid at, at least, the National Minimum Wage or National Living Wage (as applicable) for all work done, the right not to have any unlawful deductions made from their wages, the right to the statutory minimum paid holiday and rest breaks under the Working Time Regulations 1998, the right to statutory sick and statutory maternity pay, subject to qualification, the right not to be unlawfully discriminated against and the rights to the protections afforded under the Agency Workers Regulations 2010 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003.

In the tripartite relationship between the worker, the Company and the client, the Company is responsible for managing the administration relating to the engagement of the temporary agency worker. For example, the Company is responsible for paying the temporary agency worker at the agreed rate and at the agreed intervals and for making the required tax and national insurance deductions and contributions in respect of the worker, including pension. Furthermore, the Company is responsible for paying the temporary agency workers it supplies any statutory sick pay (which, from 6 April 2026, is payable from the first day of sickness absence and no longer subject to the lower earnings limit) or statutory maternity pay, subject to them qualifying for such payments in accordance with the ordinary qualifying criteria. Both the Company and the Client carry a joint responsibility, together with the temporary agency worker themselves, for ensuring the health and safety of the temporary agency worker while on assignment and the Client is responsible for supervising and controlling the actual work done by the temporary agency worker during the assignment. In addition, both parties have respective obligations to the temporary agency worker under the Agency Workers Regulations 2010.

Worker Safeguards and Recognising the Indicators of Modern Slavery

Because the Company engages and pays a large number of temporary agency workers, it operates the following safeguards to prevent and detect modern slavery among the workers it supplies:

Identity and right to work checks are carried out for every worker before they start work, in line with Home Office guidance; original identity documents are returned to the worker immediately, and the Company never retains a worker’s passport or other identity documents;
The Company does not charge work-seekers any fee for finding them work, and does not permit any third party to do so on its behalf;
Wages are paid only into a bank account held in the worker’s own name, and the Company’s systems flag cases where workers share a bank account, home address, telephone number, email address or emergency contact, which are then reviewed by Compliance;
Each worker receives a Key Information Document and written terms of engagement before starting work, together with itemised payslips, in a form they can understand;
Consultants meet or speak with each worker directly and are alert to a third party speaking for the worker, accompanying them, transporting them to work or handling their documents or wages; and
All temporary agency workers are informed of how to raise concerns confidentially, both with the Company and directly with the Modern Slavery &

Exploitation Helpline.

Staff should be alert to the indicators of modern slavery, which may include a worker who:

Appears fearful, withdrawn, malnourished or shows signs of physical or psychological abuse;
Is not in possession of their own identity documents or bank card, or is unable to say where they live;
Appears to be under the control of another person, or is always accompanied;
Has unexplained deductions from pay, or refers to debts owed to an employer, recruiter or transporter;
Lives at, or is transported to and from, the workplace with others in poor or overcrowded conditions; or
Is reluctant to take breaks or holidays, or appears to have limited freedom of movement.

The presence of one indicator does not necessarily mean that a person is a victim of modern slavery, but any concern should be reported in accordance with this Policy.

Training

The Company has an internal online Training and Development system which is used for ensuring all Staff training and development needs are met. The training provided includes sales and business development courses, people management courses, compliance training, discrimination and equal opportunities training, bribery and corruption training and many other ad hoc courses relating to specific employee or discipline requirements.

Modern slavery training forms a mandatory part of the Company’s compliance training. All Staff must complete modern slavery awareness training as part of their induction and refresher training at least annually. Staff in higher-risk roles, including consultants who register and place temporary agency workers, Compliance, payroll and those responsible for procurement, will receive enhanced training on recognising the indicators of modern slavery, carrying out the checks described in this Policy and reporting concerns. Completion of training is recorded and monitored by the Training and Development department and reported to the Board-level lead.

Annual Modern Slavery Statement

As a commercial organisation carrying on business in the UK with a total annual turnover of £36 million or more, the Company must publish a slavery and human trafficking statement for each financial year in accordance with section 54 of the Modern Slavery Act 2015. The Company will ensure that each statement:

Is approved by the board of directors and signed by a director;
Sets out the steps the Company has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its business, including information on each of the matters listed in section 54(5): (a) its organisational structure, business and supply chains; (b) its policies in relation to slavery and human trafficking; (c) its due diligence processes; (d) the parts of its business and supply chains where there is a risk of slavery and human trafficking, and the steps taken to assess and manage that risk; (e) its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against the key performance indicators set out in this Policy; and (f) the training about slavery and human trafficking available to its Staff;
Is published on the Company’s website, with a link to it in a prominent place on the homepage, within six months of the end of the financial year, with previous years’ statements remaining available; and
Is uploaded to the UK Government’s Modern Slavery Statement Registry.

Compliance is responsible for preparing the annual statement and maintaining a timetable for its approval and publication.

Related Policies

This Policy should be read together with the following Company policies:

Whistleblowing Policy;
Anti-Bribery and Corruption Policy;
Disciplinary Policy;
Recruitment, Vetting and Right to Work procedures;
Procurement and Supplier Management procedures;
Data Protection Policy; and
Health and Safety Policy.

Modern Slavery Policy